Integrity Institute Comments on DSA Election Risk Mitigation Guidelines

On March 7, 2024, the Integrity Institute submitted comments on the draft DSA guidelines on the integrity of electoral processes. The comments were submitted in response to a public consultation launched by the European Commission to gather input on the first set of guidelines drafted to support implementation of Article 35 of the DSA, which stipulates that Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) must implement mitigation measures to stem systemic risks on their platforms. 

The draft guidelines covered measures that VLOPs and VLOSEs should take in preparation for, during and after election periods, and referenced the Integrity Institute’s Best Practices for Elections Integrity guides. 

Our submission focused on strengthening the guidelines related to content-neutral design changes, such as limiting engagement based ranking, slowing virality or thwarting bad actor behaviors with addition of friction. This approach can more effectively address some of the root causes of risks we see on platforms around elections. 

Our comments were also intended to ensure that risk mitigation guidelines do not inadvertently set up systems where changes to platform algorithms or features intended to mitigate risks receive more scrutiny at platforms than changes intended to promote growth, which can significantly impact a platform’s overall risk. In addition, our comments brought forth some of the specific best practices from the guides around operational readiness, escalation processes, and interacting with external stakeholders, and added additional insights on best practices around AI.

You can read our full submission here.